ML032591152

Technical Specifications Change 425 - Framatome Fuel - Core Operating Limits Report References - Response to Request for Additional Information and TS Mark-up Correction

ML032591152
Person / Time
Site:	Browns Ferry
Issue date:	09/05/2003
From:	Abney T Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MB8433, TAC MB8434, TVA-BFN-TS-425
Download: ML032591152 (11)

Text

Tennessee Valley Authority, Post Office Box 2000. Decatur, 'abara 35609-2000 TVA-BFN-TS-425 10 CFR 50.90 September 5, 2003 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk-Mail Stop: OWFN P1-35 Washington, D.C. 20555-0001 Gentlemen:

In the Matter of) Docket Nos. 50-260 Tennessee Valley Authority 50-296 BROWNS FERRY-NUCLEAR PLANT BFN) UNITS 2 AND 3 TECHNICAL SPECIFICATIONS (TS) CHANGE-425 - FRAMAOME FUEL -CORE OPERATING LIMITS REPORT-(COLR) REFERENCES--- RESPONSE TO REQUEST FOR ADDITIONAL INFORK&TION (RAI) AND TS MARK-UP CORRECTION (TAC NOS. MB8433, MB8434)

This letter is-in response to a June 20, 2003, teleconference with the NRC staff regarding proposed BFN-TSchange 425. The proposed amendment,_which was submittedon April 14, 2003, revises two Limiting Conditions for peration regarding core thermal limits adjustments for inoperableequipment and modifies TS 5.6.5, COLR, to add references to the Frantatome Advanced Nuclear Power analytical methods that will be used to determine core operating limits.

NRC subsequently provided two-RAI questions related to the proposed TS 5.6.5 changes regardingCOLR references. The two RAI questions are repeated in Enclosure along with TVA's response.

NRrvie ubeuety woRI ustos eatdt t A correction to the TS mark-up pages provided in TVA's April 14, 2003, submittal has also been identified. The last word in the hhe new LCO 3.3.4..c should be changed from operable" to Pritnd on rEcWd

U.S. Nuclear Regulatory Commission Page 2 September 5, 2003 "applicable" for consistency with the associated TS Condition.

This is an administrative change and does not affect the purpose of the proposed TS. Replacement Unit 2 and 3 mark-up pages are provided in Enclosure 2.

TVA has determined this additional information response does not change the determination in the April 14, 2003, TS-425 submittal that there are no significant hazards considerations associated with the proposed change and that the TS change qualifies for a categorical exclusion from environmental review pursuant to the provisions of 10 CFR 51.22(c)-(9). Additionally, in accordance with 10 CFR 50.91(b)(1), TVA is sending a copy of this letter and the Enclosure to the Alabama State Department of Public Health.

There are no regulatory commitments associated with this submittal. This letter is being sent in accordance with NRC Regulatory Issue Summary 2001-05, Guidance on Submitting Documents to the NRC by Electronic Information Exchange or on CD-ROM. If you have any questions about this submittal or TS-425, please contact me at (256) 729-2636.

I declare under penalty of perjury that the foregoing is true and correct. Executed on September 5, 2003.

St cere 5yt T. E. Abney Manager Licensing and dustry Affai s Enclosu es:

1. Res nse to est for Additional Information (RAI)

2. Correc e S Pages (mark-up)

Enclosures cc (Enclosures):

State Health Officer Alabama State Department of Public Health RSA Tower - Administration Suite 1552 P.O. Box 303017 Montgomery, Alabama 36130-3017

Enclosure 1 Technical Specifications (TS) Change 425 Framatome Fuel - Core Operating Limits Report (COLR)

References Units 2 and 3 Response to Request for Additional Information NRC Question 1 Since the licensee is planning a transition to Framatome ANP fuel while still keeping some of the previous fuel in the core, the licensee will retain the existing reference to the Global Nuclear Fuels topical. In the modified version of TS 5.6.5.b, after the reference to NEDE-24011-P-A, General Electric Standard Application for Reactor Fuel, the licensee requests the removal of the statement latest approved version for BFN." Please provide justification for removing this statement from the reference document. What-version of this document will be used for the upcoming fuel cycle, and is it the most recent?

TVA Response As discussed in the April 14, 2003, TS-425 submittal, the proposed change to TS 5.6.5.b-adopts the syntax of TS Task Force (TSTF) Traveler 363. TSTF-363 was approved by NRC on July 6, 2000, and provides that only the titles of the analytic methods be included in TS 5.6.5.b and that the complete identification (report number, title, revision, date, and any supplements) be maintained in the Core Operating Limits Report COLR).

Therefore, the removal of the existing phrase "latest approved version for BFN" after the reference to NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel", is being made to stay consistent with the TSTF. By adopting TSTF-363, BFN is updating this section of TS to the latest NRC-approved version of NUREG-1433 Revision 2, "Standard TS for BWR/4s."

The existing TS 5.6.5.b reference to the Global Nuclear Fuels (GNF) (formerly General Electric) topical report, NEDE-24011-P-A, will be retained pending the complete replacement of GNF fuel with Framatome Advance Nuclear Power (FANP) fuel, since some GNF-derived core limits will continue to be applicable for

co-resident GNF fuel. NEDE-24011-P-A-14 is the latest version approved for use by NRC for BFN.

NRC Question 2 In the TS section 5.6.5 Core Operating Limits Report part (a),

four limits and setpoints are listed which the licensee calculates for each reload cycle. The licensee requests the addition of 16 approved methodologies in 5.6.5.b which will be used to calculate these limits. The licensee has not provided any indication of which individual methodologies it plans on using to calculate each limit. Please provide the staff with a table indicating which methodology will be used to calculate each limit for each fuel assembly type during the fuel transition.

TVA Response A table is provided in Attachment A, which shows the 16 FANP references added to TS 5.6.5.b by TS-425 and the associated TS 5.6.5.a Limiting Conditions for Operation-for the core limits or setpoints for which the methodology is used. Additionally, Attachment B shows the applicability of the retained reference, GNF topical report NEDE-24011-P-A, to the TS 5.6.5.a core limits.

Details regarding GNF methods for calculating core limits are available in NEDE-24011-P-A-4, June 2000.

2

Attachment A BWR Approved Framatome Advanced Nuclear Power (FANP) Topical Reports for TS-425 COLR References Report Applicable LCO / Assembly Methodology / Justification Types XN-NF-81-58(P)(A) and Supplements 1 and 2, 3.2.1 / A1O Provides an analytical capability to predict BWR fhel thermal and mechanical I Revision 2 RODEX2 Fuel Rod Thermal-Mechanical 3.2.2 / AlO, GE13, GE14 conditions for normal core operation and to establish initial conditions for power Response EvaluationModel. 3.2.3 / A10 ramping, non-LOCA, and LOCA analyses. i i

XN-NF-85-67(P)(A) Revision 1, Generic 3.2.3 / A10 Describes the process used to develop linear heat generation rates for fnel designs.

MechanicalDesignfor Exxon NuclearJet Pump I BWR Reload Fuel.

EMP-85-74(P) Revision 0 Supplement l(P)(A) and 3.2.3 J AlO Extends the exposure limit ofthe RODEX2A code which is a version of RODEX2 1 Supplement 2(P)(A), RODEX2A (BWR) Fuel Rod that includes a fission gas release model specific to BWR fuel designs.

Thermal-MechanicalEvaluationModels. i' r ANF-89-98(P)(A) Revision 1 and Supplement 1, 3.2.3 I A10 Establishes a set of design criteria which assures that BWR ffel will perfori Generic MechanicalDesign Citerafor B WR Fuel satisfactorily throughout its lifetime.

Designs.

XN-NF-80-19(P)(A) Volume I and Supplements 1 3.2.1 / A1O Development of BWR core analysis methodology which comprises codes for fuel and 2, Exxon NuclearMethodologyfor Boiling 3.2.2 / AlO, GE13, GE14 nentronic parameters and assembly brnup calculations, reactor core simulation Water ReactorsNeutronic Methodsfor Design and 3.2.3 / AlO diffnsion theory calculations, core and channd hydrodynamic stability predictions, Analysis. 3.3.2.1, Table 3.3.2.1-1 / and producing input for nuclear plant transients. Subsequently approved codes or A1O, GE13, GE14 methodologies have superceded portions ofthis reporL Applicable portions include CRDA, and methodology to determine nentronic reactivityparameters, void reactivity, Doppler reactivity, scram reactivity, delayed neutron fraction, and prompt neutron lifetime.

XN-NF-80-19(P)(A) Volume 4 Revision 1, Eaxon 3.2.1 / AlO Summarizes the types of BWR licensing analyses performed, identifies the NuclearMethodologyfor Boiling Water Reactors: 3.2.2 / AlO, GE13, GE14 methodologies used.

Application of the ENC Methodology to BWR 3.2.3 / AlO Reloads.

Attachment A 0

BWR Approved Framatome Advanced Nuclear Power (FANP) Topical Reports for TS-425 COLR References Report Applicable LCO / Assembly Methodology / Justification Types EM-2158(P)(A) Revision 0, Siemens Power 3.2.2 / AlO, GE13, GE14 Describes the reactor core simulator code MICROBURN-B2 and the lattice physics CorporationMethodologyfor Boiling Water 3.2.3 / AlO code CASMO-4.

Reactors: Evaluation and Validation of 3.3.2.1, Table 3.3.2. 1-1 /

CASMO-4/1MCROBURN-B2. AIO, GE13, GE14 XN-NF-80-19(PXA) Volume 3 Revision 2, Exxon 3.2.2/ AlO, GE13, GE14 Provides overall methodology for determining a MCPR operating limit.

NuclearMethodologyfor Boiling WaterReactors, ThERMEX: Thermal Limits Methodology Summary Description.

XN-NF-84-105(P)(A) Volume 1 and Volume 1 3.2.2 / Al1, GE13, GE14 Provides a capabilityto perform analyses oftransient heat transfer behavior in BWR Supplements I and 2, XCOBRA-T: A Computer Code assemblies.

for BWR Transient Thernal-HydraulicCore Analysis.

ANF-524(P)(A) Revision 2 Supplements 1 and 2, 3.2.2/ AlO, GE13, GE14 Provides a methodology for the determination of thermal margins, specifically the ANF CriticalPowerMethodologyfor Boiling Water MCPR safety limit Reactors.

ANF-913(P)(A) Volume 1 Revision I and Volume 1 3.2.2 I AlO, GE13, GE14 Provides a computer program for analyzing BWR system transients Supplements 2, 3 and 4, C0TRANSA2: A Computer ProgramforBoiling Water Reactor Transient Analyses.

ANF-1358(P)(A) Revision 1, The Loss of Feedwater 3.2.2 / AlO, GE13, GE14 Presents a generic methodology for evaluating the loss of feedwater heating event Heating Transient n Boiling Water Reactors.

Attachment A BWR Approved Framatome Advanced Nuclear Power (FANP) Topical Reports for TS-425 COLR References Report Applicable LCO / Assembly Methodology / Justification Types EMF-2209(P)(A) Revision 1, SPCB CriticalPower 3.2.2 / AIO, GE13, GE14 Presents an improved critical power corrdation for use with the ATRIUM-10 fnel Correlation. designs.

EMI-2245(P)(A) Revision 0, Application of Siemens 3.2.2 / GE13, GE14 Provides direct and indirect approaches to develop parameters necessary to Power Corporation'sCriffcal Power Correlationsto appropriately model co-resident fhel with an approved critical power correlation.

Co-Resident Fuel.

EMP-2361(P)(A) Revision 0, EXEMBWR -2000 3.2.1 / AlO Describes an upgraded evaluation model methodology for licensing analyses of ECCS EvaluationModel. postulated LOCAs in jet pump BWRs. The methodolOgy was developed to comply with 10 CFR 50.46 and Appendix K criteria to 10 CPR 50.

EMP-2292(P)(A) Revision 0, ATPJUAluw-0: 3.2.1 AlO Provides measured cladding temperatures from sprayheat transfer tests to justify the Appendix K Spray Heat TranerCoefficients. use of Appendix K coefficients for ATRIUM-10 fuel LOCA analyses.

Attachment B GESTAR-U COLR Limits for General Electric Fnel Applicable for a Transition Core with FANP Fuel TS-425 COLR References Applicable COLR GESTAR-I[ Applicability LCO / Assembly Types Specified Limit 3.2.1/ GE13, GE14 Average Planar Linear Heat Generation GESTAR-HI APLHGR limits documented in the BF3 Cycle 11 COLR remain applicable for GE13 Rate (APLHGR) and GE14 fd in the Cycle 12 transition core with FANP fuel.

The GESTAR-IH APLHGR limits are applied to off-rated power and flow conditions using ARTS factors MAPFAC, and MAPFACQ.

The GESTAR-il APLHGR limits are applied to the following Equipment Out-of-Service (EOOS) conditions-

• SLO (TS 3.4.1)

• Turbine Bypass OOS (TS 3.7.5) 3.2.2 / Not Applicable Minimum Critical Power Ratio (MCPR) GESTAR-II will not be applied to establish MCPR operating limits.

OLMCPR for rated and off-rated power and flow conditions and EOOS operation will be established for GE13 and GE14 fel using FANP-approved methods identified in Attachment A.

3.2.3 / GED3, GE14 Linear Heat Generation Rate (LHGR) GESTAR-Il LHGR limits documented in the BF3 Cycle 11 COLR remain applicable fbr GE13 and GE14 fel in the Cyvle 12 transition core with FANP el.

No off-rated power or flow-dependent or EOOS corrections are applied to the LHGR limits for GE fed.

3.3.2.1 Table 3.3.2.1-1/ Rod Block Monitor (RBM) setpoints and GESTAR-Il will not be applied to establish RBM setpoints and applicable reactor thermal power Not Applicable applicable reactor thermal power ranges ranges.

The RBM setpoints and applicable thermal power ranges will be established using FANP approved methods identified in Attachment A.

Enclosure 2 Technical Specifications (TS) Change 425 Framatome Fuel - Core Operating Limits Report (COLR) References Units 2 and 3 Corrected-Pages (mark-up)

4 1 1 -.

EOC-RPT Instrumentation 3.3.4.1 3.3 INSTRUMENTATION 3.3.4.1 End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation LCO 3.3.4.1 a. Two channels per trip system for each EOC-RPT instrumentation Function listed below shall be OPERABLE:

1. Turbine Stop Valve (TSV) - Closure; and

2. Turbine Control Valve (TCV) Fast Closure, Trip Oil Pressure

- Low.=

OR

b. LCO 3.2.2, "MINIMUM CRITICAL POWER RATIO (MCPR),"

limits for inoperable EOC-RPT as specified in the COLR are made applicable; Cwd APPLICABILITY: THERMAL POWER 2 30% RTP.

c. LCO 3.2.3, LINEAR HEAT GENERATION RATE (LHGR),I limits for inoperable EOC-RPT as specified in the COLR are BFN-UNIT 2 3.3-30 Amendment No. 253

EOC-RPT Instrumentation 3.3.4.1 3.3 INSTRUMENTATION  :

3.3.4.1 End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation LCO 3.3.4.1 a. Two channels per trip system for each EOC-RPT instrumentation Function listed below shall be OPERABLE:

1. Turbine Stop Valve (TSV) - Closure; and

2. Turbine Control Valve (TCV) Fast Closure, Trip Oil Pressure

- Low.

OR

b. CO 3.2.2, MINIMUM CRITICAL POWER RATIO (MCPR),"

limits for inoperable EOC-RPT as specified in the COLR are made applicable; en d &

THERMAL POWER 2 30% RTP.

BFN-UNIT 3 3.3-30 Amendment No. 213 September 03, 1998